Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
The court held that the officer failed to consider the petitioner's case that the amount received in February 2024 was erroneously described as an advance, which was rectified by filing an amended return. This aspect was not considered while passing the order rejecting the refund claim. Consequently, the order was quashed, and the respondents were directed to reconsider the petitioner's refund application after affording an opportunity of hearing within two months from the date of receipt of the court's judgment.
The court held that the officer failed to consider the petitioner's case that the amount received in February 2024 was erroneously described as an advance, which was rectified by filing an amended return. This aspect was not considered while passing the order rejecting the refund claim. Consequently, the order was quashed, and the respondents were directed to reconsider the petitioner's refund application after affording an opportunity of hearing within two months from the date of receipt of the court's judgment.
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